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Legal and Privacy Policy

 

We respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit this website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

 

Important Information and Who We Are

 

Purpose of this privacy notice

This privacy notice aims to give you information on how KCI collects and processes your personal data through your use of this website, including any data you may provide through this website.

 

Controller

 

The respective contracting party of Distributor in form of the respective PCM certified trainer/coach/recruiter or the respective contracting party of the PCM certified trainer/coach/recruiter in form of its respective customer.

 

Sub-Processor

 

Kahler Communications, Inc. is the sub-processor (collectively referred to as "KCI", "we", "us" or "our" in this privacy notice).

 

Contact details

Our full details are:

 

Kahler Communications, Inc.

PO BOX 210555

Nashville TN 37221-0555

Phone: (501) 276-0688

Email: info@kahlercommunications.com

 

Head Office:

Le Moulin Du Béchet

27120 Croisy-sur-Eure

France

 

President: Cyril Collignon

 

 

Changes to the privacy notice and your duty to inform us of changes

This version was last updated in April 2021.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

 

Purpose of this privacy notice

 

This privacy notice aims to give you information on how KCI processes your personal data through your use of this website, including any data you may provide through this website.

 

 

The data we collect about you

 

The purpose of the collection and Processing of the Customer Data by KCI is the provision, hosting, storage and support of the platform and database on which the Customer needs are conducted.

Including: Name, e-mail address, firm and feedback to the provided questionnaire on the Data Subject’s personality,  Controller’s customers and/or such customer’s employees.

 

If you fail to provide personal data

 

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

 

How is your personal data collected?

 

We use different methods to collect data from and about you including through:

 

Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise.

 

Automated technologies or interactions. As you interact with this website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

 

How we use your personal data

 

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

 

• Where we need to perform the contract we are about to enter into or have entered into with you or with the Data Controller or the PCM Distributor.

 

• Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.

 

• Where we need to comply with a legal or regulatory obligation.

 

Please see the Glossary at paragraph 10 to find out more about the types of lawful basis that we will rely on to process your personal data.

 

Cookies

 

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

 

Change of purpose

 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

 

Disclosures of your personal data

 

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

 

Internal third parties

 

• Other companies in the Kahler Communications Group based within the EEA.

 

External third parties

 

• IT and system administration service providers based within the EEA.

 

• Data storage provider based in France.

 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

International transfers

 

 

For all EEA residents, we do not transfer personal data to a country outside the EEA.

 

KCI does not provide any data to third parties other than the local Process Communication Model distributor and their network of PCM Trainer/Coach/Recruiters.

 

KCI does not transmit any data to a third country, unless you are a resident of that country and are dependent on a local distributor. In that case, only he or she has access to your data.

 

Please remember that this Privacy Policy does not cover any data processing for which you may be responsible as a result of using our services. You, or the party you represent, are always responsible for your personal data processing in accordance with applicable law.

 

 

Data security

 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

Data retention

 

How long will you use my personal data for?

 

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

 

Your personal data is kept for a maximum of three years then anonymised.

 

In some circumstances you can ask us to delete your data: see paragraph 9 below for further information.

 

In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

Your legal rights

 

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see Glossary to find out more about these rights.

 

If you wish to exercise any of the rights set out, please contact us at info@kahlercommunications.com

 

No fee usually required

 

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

 

What we may need from you

 

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

 

Time limit to respond

 

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

Glossary

 

LAWFUL BASIS

 

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

 

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

 

YOUR LEGAL RIGHTS

 

You have the right to:

 

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

 

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

 

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

 

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

 

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

 

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

 

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide services to you. We will advise you if this is the case at the time you withdraw your consent.

 

 

 

 

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